portfolio interest
(3)For purposes of this subsection, the term “portfolio interest” shall not include any portfolio interest which— (A)except in the case of interest paid on an obligation of the United States, is received by a bank on an extension of credit made pursuant to a loan agreement entered into in the ordinary course of its trade or business, (B)is received by a 10-percent shareholder (within the meaning of), or (C)is received by a controlled foreign corporation from a related person (within the meaning of).